Our Commitment to Privacy
IGEG Investments Privacy Policy
-How and why we obtain and use personal information
-How we protect information about you
-How we share information about you with third parties
-How we share information about you with our affiliates
-Your digital privacy
-Additional information
*Additional Information for California Residents
*IGEG Companies Covered by this Privacy Policy
*IGEG Funds Privacy Policy
Our commitment to privacy
IGEG Investments and the IGEG Funds recognize the importance of maintaining the privacy of personal information about our current and prospective customers.
As used in this privacy policy, personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy.
Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether IGEG provides services to your employer or plan sponsor. In addition, some of IGEG's products, services or digital offerings may have a different or additional privacy policy which may be made available to you if you choose to use those products, services or digital offerings.
This policy is reviewed annually and updated to reflect any changes.
IGEG Investments privacy policy
How and why we obtain and use personal information
IGEG recognizes the importance of maintaining personal information about you and when we use it, we do so with respect for your privacy. We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; operate and manage our business; and fulfill legal and regulatory requirements. IGEG collects public and non-public personal information from customers and visitors from various sources. Some examples include:
You or your representative on applications or forms (for example, when you interact with our customer service staff, and when you visit our websites or use our applications)
You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our websites)
You or your employer or plan sponsor if IGEG provides them with recordkeeping and/or employee benefits advisory services (for example, payroll, human resources, or benefits information)
Transactional activity in your account (for example, trading history and balances)
Other interactions with IGEG (for example, discussions with our customer service staff, including telephone or chat, information you enter into our websites, or when you enroll in our authentication services)
Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
Information from other third-party sources (for example, to verify your identity and to better understand your product and service needs)
Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into IGEG)
How we protect information about you
We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology.
At IGEG, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you and to operate our business.
How we share information about you with third parties
IGEG does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:
Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at IGEG's direction)
Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
Other third-parties, with your consent or as directed by your representative (for example, if you request to transfer assets from another financial institution, or if you use an external aggregation website or service that you have provided permission to access your IGEG financial account on your behalf)
Other third parties whose products, services and investment offerings are made available through IGEG, and which you decide to utilize
Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)
In connection with corporate business transactions, such as a merger or sale of a business.
Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by IGEG.
In addition, if you choose to use or indicate your interest in using a product, service or investment offering that is offered by a third party and made available through IGEG, we may share personal information with that third party in connection with your use or interest of that product, service or investment offering.
Based on the nature of your relationship with IGEG, we may exchange information with other third parties as described below:
If IGEG provides workplace services to your employer or plan sponsor, such as payroll, human resources or employee benefits advisory and/or recordkeeping services, IGEG may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
If you conduct business with IGEG through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
If you transact business through IGEG's life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.
How we provide information about you with our affiliates
We may provide personal information about you to various IGEG corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.
If you interact with IGEG directly as an individual investor (including joint account holders), we may provide certain information about you to IGEG affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.
Where IGEG provides services to you under an arrangement with your employer or plan sponsor, to the extent permitted by you or under our agreement with your employer or plan sponsor and as allowed by law, we may provide information about you to IGEG's affiliates, such as our brokerage and insurance companies, for their use in marketing products and services.
Information collected from investment professionals' customers is not provided to IGEG affiliates for marketing purposes, except with your or your representatives' consent and as allowed by law.
Your digital privacy
When you interact with us by using our websites, online services or applications (including mobile apps) that are owned and controlled by IGEG Investments ("our digital offerings"), or via electronic communications, IGEG manages personal information in accordance with all of the practices and safeguards described in this policy.
When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience. Additionally, the following policies and practices apply when you are online.
Cookies and similar technologies
IGEG and our third-party service providers may use cookies and similar technologies ("cookies") to support the operation of and maintain our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. IGEG cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.
Both IGEG and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies.
We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings and to understand more about the demographics of our users. You can learn more about Google's practices with Google Analytics by visiting Google's privacy policy. You can also view Google's currently available opt-out options.
Advertising on IGEG Digital Offerings
IGEG advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about IGEG and third-party products and services that may be of interest to you.
We may also use third-party service providers to help us determine which IGEG products and services may be of interest to you. These service providers may use cookies and other technologies to collect for us information about your activity on IGEG digital offerings. We and our service providers use such information to analyze the effectiveness of our advertising and the usage of our digital offerings. For example, we may analyze the browsing patterns while visiting a IGEG website and responses to advertisements and promotions shown on our digital offerings. Such service providers may only collect and use such information for purposes specified by IGEG and not for their own purposes.
Advertising on Non-IGEG Digital Offerings
IGEG also advertises our products and services on digital offerings not affiliated with IGEG and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.
IGEG and these third-party online advertising companies may use the data collected, along with other information we have about you and your IGEG relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on IGEG and non-IGEG websites. These advertisements are known as "interest-based advertisements".
You may opt-out of receiving interest-based advertisements from online advertising companies, including those used by IGEG, by clicking on the AdChoices icon and following the opt-out instructions.
If you generally want to "opt out" of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in a self-regulatory programs like the Digital Advertising Alliance DAA program or the Network Advertising Initiative (NAI), please follow the instructions at WebChoices: Digital Advertising Alliance's Consumer Choice Tool for Web US (aboutads.info) and NAI Consumer Opt Out (networkadvertising.org) to place an "opt-out" cookie on your device indicating that you do not want to receive interest-based advertisements. If you want to "opt out" of receiving online interest-based advertisements on mobile devices, please follow the instructions at YourAdChoices.com | AppChoices and Mobile Opt Out - NAI: Network Advertising Initiative (thenai.org).
Connecting with IGEG on social media platforms
IGEG provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.
Third Party websites, online service, and content
Our digital offerings may contain links to third party websites and online services (for example, social media platforms) and may include embedded content that is hosted by third parties. This policy does not address the privacy, security, cookie policy and settings, or other practices of the third parties that provide such websites, online services, or content, and we are not responsible for the privacy practices or the content of these other websites, online services, or content providers. If you use a link to another website or online service or view third party content (for example, an embedded video), please consult the privacy policy for that website/or online service for additional information on their privacy practices and advertising opt-out instructions.
Children's privacy
In general, IGEG's digital offerings are not directed to individuals under the age of thirteen (13). IGEG does not intentionally collect information on IGEG websites from those we know are under 13, and we request that these individuals do not provide personal information through our digital offerings. If we do provide a digital offering that is intended to be used by individuals under the age of thirteen, it will have a separate privacy policy.
Additional information
If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.
IGEG offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or our digital offerings. You may also write or call us with your request for information. If you transact business through IGEG's life insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.
Additional Information for California Residents
This section is provided for purposes related to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CPRA") and applies solely to the personal information and IGEG companies that are subject to the CPRA. As used in this section, "personal information" means information that meets the definition of "personal information" as set forth in the CPRA and is not otherwise excluded from the scope of the CPRA.
IGEG companies and the CPRA
Depending on the IGEG company with which you have a relationship or otherwise interact, the nature of your relationship and interactions with that IGEG company, and the products and services provided to you through that relationship, some or all of the personal information that the IGEG company collects or maintains is covered by one or more of the exemptions described below (see the section below entitled "CPRA Exemptions"). As a result, in some cases, the applicable IGEG company may have no obligation under the CPRA to accept any CPRA requests, and in other cases, it may have no obligation to honor a particular CPRA request, because of the nature of the personal information that the IGEG company collects or maintains. Here are some examples of CPRA exemptions:
If your relationship and interactions with a IGEG company consist solely of personal financial services (e.g., maintaining one or more personal brokerage accounts), the personal information collected and processed about you is subject to the federal Gramm-Leach-Bliley Act ("GLBA") and therefore your CPRA request will not be honored by the IGEG company.
If you participate in a workplace retirement plan, or other employee benefit plan sponsored by or provided through your employer, that is serviced or administered by a IGEG company, CPRA requests should be directed to your employer.
Your Rights Under the CPRA
The CPRA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CPRA. As required by the CPRA, set forth below is a description of certain rights that California residents generally have under the CPRA. As used below, a "consumer" means a resident of the State of California and a "covered business" means a business that is subject to the CPRA.
Right to Know/Right to Access. A consumer has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the following:
The categories of personal information it has collected about that consumer
The categories of sources from which the personal information is collected
The business or commercial purpose for collecting, selling or sharing (if applicable) personal information
The categories of third parties to whom the covered business discloses personal information
The specific pieces of personal information that the covered business has collected about that consumer
These disclosures are not required to include any information about activity that occurred prior to January 1, 2022. Please also note that a covered business is not required to honor more than 2 of these requests from the same consumer during any 12-month period.
Right to Delete. A consumer has the right to request that a covered business delete any personal information that the business has collected from the consumer, subject to certain exceptions.
Right to Correct. A consumer has the right to request that a covered business correct inaccurate personal information that a business maintains about a consumer.
Right to Opt-Out of Sale/Sharing. If a covered business sells or shares personal information, a consumer has the right to opt-out of the sale or sharing of their personal information by the business.
Right to Limit Use and Disclosure of Sensitive Personal Information. If a covered business uses or discloses sensitive personal information for reasons other than those set forth in the CPRA, a consumer has the right to limit the use or disclosure of sensitive personal information by the business.
Non-Discrimination. A consumer has the right not to receive discriminatory treatment by the covered business for the exercise of privacy rights conferred by the CPRA.
Categories of personal information we may collect about you
In general, if you are a customer of ours or you otherwise interact with us, we collect various types of personal information about you. The amount and types of personal information we collect will vary depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you. The categories of personal information that we may collect about you are:
Personal identifiers, such as your name, postal address, email address, online identifier, internet protocol address, account name, or other similar identifiers
Information covered by California's records-destruction law (California Civil Code §1798.80), such as your signature, telephone number, and financial account information
Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Characteristics of protected classifications under California or federal law
Biometric information, such as when you use our voice-recognition service that we use for identity-verification and security purposes
Internet or other electronic network activity information, including, but not limited to, browsing history and search history while using our digital offerings, and other information regarding your interactions with our digital offerings or our advertisements
Geolocation data
Audio, electronic, visual, and similar data, such as call recordings
Professional or employment-related information, such as job title and business contact information
Education information
Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes
Sensitive personal information such as social security number, or account log-in, password or credentials allowing access to your account(s) or to our digital offerings
The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, for legal defense purposes and to comply with legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services.
Categories of sources from which personal information is collected
In addition to the sources described in the section above entitled "How and why we obtain and use personal information", depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we may obtain personal information from the following sources:
You or your representative, such as when using our products, services or digital offerings, when interacting with us or any of our service providers regarding our products, services or digital offerings or when otherwise communicating with us
Providers of publicly available information
Another person or other persons (typically people who know you) who provide referral information about you to us or who use the capabilities we offer on certain of our websites and applications to forward an article or other information to you
Third parties that provide products and services to you through your relationship with us
Third parties that perform services for us or on our behalf
Other third-party sources, including government sources, data brokers and social networks
Automatically, via technologies such as cookies and web beacons, when you interact with our digital offerings or electronic communications
Why we collect personal information
Please see the section above entitled "How and why we obtain and use personal information" for a description of some of the business or commercial purposes for which we collect personal information, including sensitive personal information. In addition to those purposes described above, below are additional business or commercial purposes for which we collect personal information:
To provide you with information about products and services that may interest you
To maintain the accuracy and integrity of our records
For marketing and communication purposes
For reporting and analytical purposes
For personalizing your interactions and experiences with us
For training and quality-control measures
To verify your identity
To protect against malicious, fraudulent, or illegal activity
For business analysis, planning, and reporting
For customer education
For effectiveness measurements
Categories of personal information disclosed for business purposes
Like most businesses, we disclose personal information, including in some cases certain sensitive personal information, to third parties for our business purposes. Depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we disclose to third parties for business purposes the personal information that is encompassed by one or more of the categories described in the "Categories of personal information we may collect about you" section above, with the categories of third parties listed in the section above entitled "How we share information about you with third parties".
Selling/sharing of personal information
We DO NOT sell your personal information for payment or for any other compensation. However, some of the ways in which we share your personal information with third parties on certain of our Websites may, under the CPRA, be considered to be a “sale” of personal information or “sharing” of personal information for “cross-context behavioral advertising” (as those terms are used in the CPRA).
We engage third party service providers, including marketing and advertising providers, and social media platforms (providers) to personalize your browsing experience on our Websites, to provide certain targeted advertising services for us, and to help us measure the effectiveness of our Websites and our online advertising. When you visit our Websites, we and our providers collect certain information about your activity on our Websites, including cookies and similar data stored on or collected from your browser or device. In some cases, our providers may combine this information collected on our Websites with information about your activity on other, unaffiliated websites or social media platforms to deliver our ads to you when you are visiting other websites or platforms. This sharing of your information with certain third parties via cookies and similar methods, and our providers' use of certain cookies, may be considered to be a "sale" of personal information or "sharing" of personal information for "cross-context behavioral advertising" under the CPRA.
California residents covered by the CPRA have the right to opt out of this "sale" or "sharing" of personal information. For those Websites where we engage in these activities and are covered by the CPRA, if we determine that you are visiting the Website from a location in California, you will see a "Do Not Sell or Share my Personal Information" link on the footer of the Website's homepage. To opt out of this sale or sharing of your personal information, please click on the link and follow the prompts.
Note that IGEG permits all visitors to certain portions of our IGEG.com website (for example, the homepage at www.IGEG.com) to automatically exercise their right to opt-out of this sale or sharing of this personal information through the use of the Global Privacy Control (GPC) signal without having to make individualized opt-out requests. If you've enabled the GPC signal in your browser, we will honor your request to opt-out of this sale or sharing of personal information as communicated via the GPC signal. These opt-outs (whether via the toggle above or via the GPC signal) are a setting that is specific to the device or browser you're using. You'll need to opt out again if you visit our applicable Websites from a different device or browser, change your browser settings, or clear your cookies.
In the 12 months preceding the date of this Notice, we "sold" and/or "shared" personal information for "cross-context behavioral advertising", with respect to California residents covered by the CPRA. We do not knowingly "sell" or "share" for "cross-context behavioral advertising" personal information of minors under 16 years of age.
CPRA Exemptions
Please note that certain types of personal information collected or maintained by a covered business are exempt from the CPRA. For example, a covered business has limited obligations, or in some cases, no obligations, under the CPRA with regard to the following types of personal information:
Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) and implementing regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 [commencing with Section 4050] of the California Financial Code)
Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate pursuant to the Health Insurance Portability and Accountability Act of 1996.
In addition, some businesses are not subject to the CPRA, such as:
A business that does not do business in the State of California
A business that is not organized or operated for the profit of financial benefit of its shareholders or other owners
A business that does not determine the purposes and means of the processing of consumers' personal information
A business that has annual gross revenue of $25,000,000 or less
Furthermore, under the CPRA, there are a number of situations where a covered business under the CPRA may refuse to honor a CPRA request to delete a consumer's personal information and is allowed to continue to maintain the personal information. Some examples include situations where retention of the personal information is reasonably necessary to:
Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer or reasonably anticipated within the context of the covered business’s ongoing business relationship with the consumer, or otherwise perform a contract between the IGEG company and the consumer
Help to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for those purposes
Debugging to identify and repair errors that impair existing intended functionality
Exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided by law
To enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer's relationship with the business and compatible with the context in which the consumer provided the information
Comply with a legal obligation
Please note that the description of the CPRA set forth in this privacy policy is a summary of only certain aspects of the CPRA and is not and should not be considered a complete description of the CPRA. In addition to what is described above, the CPRA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer’s request to delete the consumer's personal information.
Submitting a CPRA Request
If you wish to submit a CPRA request to any of the IGEG companies listed in this privacy policy, you may initiate your request through one of the options provided on our California Privacy Rights Request Page. Before submitting your request, please ensure you have reviewed all the CPRA exemptions, including those described above under the section above entitled "CPRA Exemptions".
You should generally expect to receive a response within 45 days of the date we receive your request. However, in some instances, we may require an additional 45 days to process your request in which case we will notify you and explain why the extension is necessary.
We will need to verify your identity before we can process your request. Through the request process, we will make you aware of any information that you will need to provide to us to process your request. You may have to confirm that you are a California resident and verify your identity or the identities of those authorized to submit requests on your behalf. Additionally, the information you provide will be used to help verify your identity.
To understand how you can designate an authorized agent with the ability to make a request under the CPRA on your behalf, please refer to our California Privacy Rights Request page.
IGEG companies covered by this privacy policy received 12 CCPA requests for disclosure of personal information (request to know) and 18 CCPA requests for deletion of personal information (request to delete) between January 1, 2021 and December 31, 2021. IGEG companies responded to each of these requests in an average of 10.46 days. However, because of exemptions under the CPRA, IGEG companies did not comply with any of these requests.
IGEG Companies Covered by this Privacy Policy
The IGEG Investments privacy policy is provided on behalf of: IGEG Brokerage Services LLC
IGEG Distributors Company LLC
IGEG Diversifying Solutions LLC
IGEG Workplace Services LLC
IGEG Investments Institutional Operations Company, Inc.
IGEG Management Trust Company
IGEG Personal Trust Company, FSB
IGEG Personal and Workplace Advisors LLC
IGEG Stock Plan Services, LLC
IGEG Institutional Wealth Adviser LLC
IGEG Investments Life Insurance Company
Empire IGEG Investments Life Insurance Company
IGEG Health Insurance Services, LLC
IGEG Insurance Agency, Inc.
IGEG Wealth Technologies LLC
FIAM LLC
National Financial Services LLC
Strategic Advisers LLC
Other companies owned by IGEG Investments using the IGEG name to provide financial or payroll services to customers
IGEG Funds Privacy Policy
Protecting your personal information is an important priority for the IGEG Funds. The Funds' privacy policy is designed to support this objective. The Funds collect non-public personal information concerning you in the following ways:
Information provided by you or your representative on applications or other forms furnished to the Funds or through other interactions that you or your representative have with the Funds
Information arising from your investments in or accounts with the Funds
Information the Funds receive from a consumer reporting agency
The Funds employ physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.
The Funds do not disclose any non-public personal information about you, except as permitted by law. For example, the Funds have entered into a number of arrangements with IGEG Investments to provide for investment management, distribution and servicing of the Funds.
If you decide to close your account, the Funds will continue to adhere to the privacy policies and practices as described in this policy.
Please read the IGEG Funds Privacy Policy in conjunction with the Privacy Policy for the IGEG Investments companies of which you are also a customer.
The IGEG Funds Privacy Policy is provided on behalf of the IGEG Investments family of mutual funds, including those advised by Strategic Advisers LLC.
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